AFFIDAVIT OF DR. TAMER BA§AR
`
`I, Dr. Tamer Basar, declare as follows:
`
`1.
`
`I am employed by the University of Illinois at Urbana—Champaign
`
`(“UIUC”). My address is 206 Center for Advanced Study, Levis Faculty
`
`Center—Suite 200, University of Illinois, 919 West Illinois Street MC-064,
`
`Urbana, Illinois 61 80 1 .
`
`2.
`
`I received a B.S.E.E. degree from Robert College, Istanbul, in 1969, and
`
`M.S., M.Phil, and Ph.D. degrees in engineering and applied science from
`
`Yale University, in 1970, 1971 and 1972, respectively. I joined the
`
`University of Illinois at Urbana—Champaign in 1981.
`
`3.
`
`I am currently Director of the Center for Advanced Study at the University
`
`of Illinois at Urbana—Champaign. I am also the Swanlund Endowed Chair
`
`for the University of Illinois at Urbana—Champaign, Department of Electrical
`
`and Computer Engineering.
`
`I also hold several professorship positions
`
`including positions as professor of the Department of Electrical and
`
`Computer Engineering, Information Trust Institute, Mechanical Science and
`
`Engineering, and the Coordinated Science Laboratory.
`
`4.
`
`For over 50 years, the University of Illinois at Urbana—Champaign has
`
`hosted the Annual Allerton Conference on Communication, Control, and
`
`1
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1233
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1233
`
`1
`
`
`
`I, Dr. Tamer Basar, declare as follows:
`
`1.
`
`I am employed by the University of Illinois at Urbana—Champaign
`
`(“UIUC”). My address is 206 Center for Advanced Study, Levis Faculty
`
`Center—Suite 200, University of Illinois, 919 West Illinois Street MC-064,
`
`Urbana, Illinois 61 80 1 .
`
`2.
`
`I received a B.S.E.E. degree from Robert College, Istanbul, in 1969, and
`
`M.S., M.Phil, and Ph.D. degrees in engineering and applied science from
`
`Yale University, in 1970, 1971 and 1972, respectively. I joined the
`
`University of Illinois at Urbana—Champaign in 1981.
`
`3.
`
`I am currently Director of the Center for Advanced Study at the University
`
`of Illinois at Urbana—Champaign. I am also the Swanlund Endowed Chair
`
`for the University of Illinois at Urbana—Champaign, Department of Electrical
`
`and Computer Engineering.
`
`I also hold several professorship positions
`
`including positions as professor of the Department of Electrical and
`
`Computer Engineering, Information Trust Institute, Mechanical Science and
`
`Engineering, and the Coordinated Science Laboratory.
`
`4.
`
`For over 50 years, the University of Illinois at Urbana—Champaign has
`
`hosted the Annual Allerton Conference on Communication, Control, and
`
`1
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1233
`
`Apple vs. Caltech
`IPR2017-00219
`Apple 1233
`
`1
`
`
`
`Computing (“Allerton Conference”) at the Allerton Retreat Center. The
`
`Allerton Conference includes several days of technical programs by scholars
`
`on various technical subjects relating to the fields of communication, control
`
`and computing. All papers presented at the Allerton Conference are
`
`published in official Conference Proceedings each year.
`
`I have been involved with the Allerton Conference in a number of official
`
`capacities since at least 1983, and have attended the conference each year
`
`since 1983. I have also served as co-chair for the conference six times, in
`
`1983, 1984, 1997, 1998, 2012, and 2013.
`
`Both from my own participation in the conference (as a presenter and author
`
`of conference papers), and from my service as co—chair of the Allerton
`
`Conference, I have become thoroughly familiar with the schedule and
`
`practices of the Allerton Conference as they relate to the submission of
`
`papers, presentation of papers at the conference, and the publication of the
`
`Conference Proceedings.
`
`The Allerton Conference is held on an annual basis during the fall, typically
`
`at the end of September or in early October. The Allerton Conference is
`
`open to the public for attendance. Any person who wants to attend, and is
`
`able to pay the registration fee, can attend the Allerton Conference. The
`
`1998 and 1999 Allerton Conferences were among the premiere conferences
`
`2
`
`
`
`on the topic of error correction coding theory, and those who were interested
`
`in this topic would have been aware of these conferences. Before each
`
`Allerton Conference, the conference issues a call for papers on particular
`
`areas of technical interest. The deadline for initial paper submissions is in
`
`the summer before the conference. Toward the end of the summer, at least a
`
`month prior to the conference, authors are notified whether their papers are
`
`accepted for presentation at the Conference Proceedings. Those authors then
`
`present their papers during the conference itself.
`
`Authors must deposit their final papers with the conference Secretariat on
`
`the Friday morning of the conference; in some special cases, upon request by
`
`an attendee, the deposit date could be extended by a couple of days.
`
`Conference staff assembles the papers and then sends the assembled papers
`
`to a publisher for printing. The printed copies of the Conference
`
`Proceedings are shipped to all conference participants and any members of
`
`the public (including individuals and/or institutions) who have ordered a
`
`copy of the Conference Proceedings. Copies of the Conference Proceedings
`
`are also made available for purchase fiom the conference Secretariat by any
`
`member of the public as soon as printing is complete.
`
`It takes no more than four to five months from the end of the conference to
`
`the final publication and shipment of the complete Conference Proceedings.
`
`3
`
`
`
`Accordingly, the complete Conference Proceedings are published by no later
`
`than February of the year following the conference. I am aware of no
`
`instance in which the Conference Proceedings were not published by
`
`February of the year following the conference — Le. , the Conference
`
`Proceedings for the 36th Annual Allerton Conference, held in September
`
`1998, were published no later than February 1999, and the Conference
`
`Proceedings for the 37th Annual Allerton Conference, held in September
`
`1999, were published no later than February 2000. Even though I do not
`
`have an accurate record of the date, it is quite likely that I received my copy
`
`of the Conference Proceedings for the 36th Annual Allerton Conference in
`
`February 1999, and I received my copy of the Conference Proceedings for
`
`the 37th Annual Allerton Conference in February 2000.
`
`10.
`
`In addition, from the time that conference staff sends the assembled papers
`
`to the local publisher for publication, it only takes about 10 weeks for the
`
`publisher to print and ship the Conference Proceedings. As noted above,
`
`any member of the public can purchase a copy of the Conference
`
`Proceedings from the conference Secretariat as of the date printing is
`
`complete.
`
`11.
`
`Attached as Exhibit A is a true and accurate copy of a purchase order letter
`
`from Dr. Sreenivas (the co—chair of the 1999 conference) to Ms. Anderson at
`
`4
`
`
`
`the Purchasing Division of the University of Illinois at Urbana—Champaign
`
`for the 37th Annual Allerton Conference on Communications Control and
`
`Computing Proceedings (“Sreenivas Purchase Order”). The Sreenivas
`
`Purchase Order is dated December 8, 1999, and I understand that Angie
`
`Marie Ellis (Office Manager, Decision and Control Laboratory University of
`
`Illinois at Urbana—Champaign) obtained the purchase order from the Allerton
`
`Conference records. The Sreenivas Purchase Order confirms that the
`
`conference staff sent the assembled papers for the 37th Annual Allerton
`
`Conference to the local publisher for publication on or about December 8,
`
`1999.
`
`12.
`
`The Sreenivas Purchase Order is the final order from the conference before
`
`printing. Accordingly, printing of the 37th Annual Allerton Conference on
`
`Communications Control and Computing Proceedings was complete, and the
`
`Conference Proceedings shipped, about 10 weeks after the date of this letter.
`
`Based on my experience, this record confirms that the proceedings of the
`
`37th Annual Allerton Conference on Communications Control and
`
`Computing were published and shipped no later than February 2000.
`
`MM
`
`Date:
`
`July 12, 2017
`
`5
`
`
`
`EXHIBIT A
`
`6
`
`
`
`R. S. Sreenivas
`
`217/333—7735
`e—mail: rsree@uiuc.edu
`
`December 8, 1999
`
`Ms. Joan Anderson
`
`Purchasing Division
`University of Illinois at Urbana—Champaign
`207 Henry Administration Building, MC—364
`Campus Mail
`
`Re: Printing of the 37th Annual Allerton Conference on Communication, Control
`and Computing Proceedings
`
`Dear Ms. Anderson:
`
`I have reviewed the printing quotation, #Q—9192, for the printing of the 37th Annual Allerton
`Conference on Communication, Control and Computing proceedings.
`I accept the low bid from Cushing—
`Malloy, option A for $8,417.00 The final page count is 1363. The cover color is India.
`
`Quote #Q—9192 and this memo has been referenced as attachments in the EOS request number.
`
`If
`
`you have any questions, please contact either the Allerton Conference secretary, Becky Lonberger,
`becky@contorl.csl.uiuc.edu, phone 3—0282 or myself.
`
`Sincerely,
`
`R. S. Sreenivas
`
`7
`
`
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